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Personal Data Protection Policy

1. SCOPE FIELD

This Privacy Policy defines the manner in which the company Agrotiki Viomichania Messinias S.A. (hereinafter referred to as “AGRO.VI.M.” and/or the “Company”) collects, uses, processes, stores, manages, and protects personal data (hereinafter referred to as “personal data” or “PD”) of its customers, suppliers, partners, subcontractors, job applicants, and website visitors, in order to meet the Company’s data protection standards and to comply with applicable legislation. This Policy applies to any information that:

i. relates to the customer (hereinafter referred to as the “Customer”) in the context of the provision of services by AGRO.VI.M. or the development of public relations with them,
ii. relates to the supplier’s personal data in the context of commercial cooperation with AGRO.VI.M., the provision of services, or the evaluation of offers within the framework of market research,
iii. concerns the data of job applicants collected during the recruitment process
iv. concerns visitors and customers of the AGRO.VI.M. website https://agrovimsite.codemonkeys.dev/ (hereinafter referred to as the “Website”)
v. concerns customer data within the framework of customer service (complaint handling process),
vi. concerns data of visitors to the Company’s premises.

AGRO.VI.M. is committed to protecting the privacy of visitors / customers / suppliers / job applicants (natural persons), and other data subjects to whom the personal data relate, and to complying with the applicable data protection legislation.

2. CATEGORIES AND TYPES OF COLLECTED PERSONAL DATA

Collected Data

  1. CV Evaluation Process: Full name, gender, date of birth, telephone numbers, e-mail address, residential address, nationality, level of education, education and training history, ID card number, desired remuneration, employment history (work experience).
  2. Customer Personal Data Management Process within the framework of commercial cooperation: Full name, telephone numbers, e-mail address, address, Tax Identification Number (VAT number), bank account details.
  3. Supplier / Partner / Subcontractor Personal Data Management Process within the framework of commercial cooperation: Full name, telephone numbers, e-mail address, address, Tax Identification Number (VAT number), bank account details.
  4. Communication Process with Website Visitors:
    a. Via cookies: consent settings of the data subject, visitor preferences during website navigation
    b. Via contact form: full name, country, e-mail address
    c. Via newsletter subscription field: e-mail address
  5. Visitor Control Process at the Company’s premises through a video surveillance system (CCTV): Image files (moving and still images), vehicle license plate number.
  6. Offer Evaluation Process, Market Research, Customer Satisfaction Surveys, and Promotion of Products and Services (Marketing): Company/Organization, job title, work location, full name, telephone numbers, e-mail address, photographs.
  7. Email Marketing Activities Process: Full name, e-mail address. Statement regarding the Processing of Personal Data by AGRO.VI.M. (acting as Data Controller and Data Processor, in accordance with the General Data Protection Regulation EU 679/2016).

Purposes of Processing of Personal Data by AGRO.VI.M. & legal basis for data processing

AGRO.VI.M. operates in the field of standardization and trade of olives, olive oil and their derivatives. The legal basis for the processing of personal data within this framework is the performance of the respective contract (trade, export of its products), the legitimate interest of AGRO.VI.M. (indicatively in cases of processing personal data within the context of business opportunity research, offer evaluation) and, in certain cases, the consent of the data subjects (marketing activities, collection of visitor data through the website). In addition, AGRO.VI.M. may collect personal data of prospective employees who are interested in cooperating with the Company, solely for the purpose of examining the possibility of a future cooperation–employment relationship. The legal basis for the aforementioned data collection is the consent of the data subject, who provides the necessary information for their processing.

Information collected automatically during visits and interaction with the Website

The AGRO.VI.M. Website uses strictly necessary cookies, preference cookies as well as statistical analysis cookies (statistics cookies) for storing the user’s consent and preferences during browsing the Website. For a full description of the cookies used and the type of data collected through them, please refer to the section Cookies & Other Technologies.

AGRO.VI.M. does not manage, collect or process geographical location data, which are collected and processed exclusively by the companies providing operating systems for each device you use (in the case of iOS – Apple Inc. or in the case of Android – Google Inc.). AGRO.VI.M. does not have access to the GPS location refresh rate.

3. DATA COLLECTION POINT

  1. General Commercial Registry (G.E.MI. website) – B, C
  2. Sole proprietorships, customers – B, C, F
  3. Sole proprietorships, suppliers – B, C, F
  4. Job applicants -Α
  5. Video surveillance systems -Ε
  6. Website – Δ

4. RECIPIENTS AND TRANSFER OF DATA TO THIRD PARTIES

AGRO.VI.M. reserves the right to disclose the personal data of the data subjects to any member of its affiliated / subsidiary companies (parent company and its subsidiaries), which implement appropriate technical, physical, legal and administrative security measures to protect personal data against loss, misuse, damage, alteration, unauthorized access and disclosure, as provided for in Article 32 of the General Data Protection Regulation (EU) 679/2016, or to other third parties to the extent that this is reasonably necessary for the purposes set out in this Policy and in particular:

  • The personal data of the data subject will be transferred to the internal departments of AGRO.VI.M. which are responsible for the smooth and uninterrupted trading of the Company’s products, the operation of the Website, as well as for customer service in the context of the evaluation / management of their complaints / requests.
  • The personal data of the data subjects may also be transferred to and become accessible by legal entities (partners, subcontractors, etc.) with whom we enter into contractual agreements from time to time for the purpose of pursuing our statutory objective (provision of services), within the framework of the legitimate interest of our Company.
  • Personal data relating to invoicing may be transferred to and become accessible by banking institutions with which we cooperate for the processing of employee payments, as well as to the competent public authorities in the context of our compliance with a legal obligation.
  • The personal data of the data subjects may be disclosed to cloud hosting providers for the purpose of storing and safeguarding the data with appropriate technical and security measures.
  • During all data transfers, we always take all appropriate measures to ensure that the transferred data are limited to the minimum required for the intended purpose of the processing and that the conditions of lawful and valid processing are always met. The partners of AGRO.VI.M. to whom personal data may be transferred have signed the necessary data processing agreements or have provided specific guarantees regarding the transfers of personal data by applying standard contractual clauses in their agreements.

5. PERIOD OF RETENTION OF PERSONAL DATA

The period of retention of personal data depends on the lawful basis for processing, as detailed below:

  • In cases where the lawful basis for processing is the pursuit of legitimate interest, the processing and retention of personal data will be carried out for as long as deemed necessary to achieve the intended purpose of AGRO.VI.M., as well as for any additional period required until the statute of limitations for any related claims has expired.
  • In cases where the personal data of Customers are provided on the basis of their own consent in the context of submitting a CV or details via the Website contact form, or when sending e-mails to data subjects as part of e-mail marketing activities, we will retain their data until the consent granted by the data subject is withdrawn. If, for any reason, such consent is withdrawn, we will retain the data for any additional period required until the statute of limitations for any related claims has expired.
  • In cases where the lawful basis for processing is the performance of a contract, we will retain your data for as long as you maintain a contractual relationship with us, both in hard copy and electronic form, or for any additional period required until the statute of limitations for any related claims (civil, tax, etc.) has expired.
  • In cases where the processing of personal data is carried out on the basis of a legal obligation (Article 6(1)(c) of the GDPR), the retention period is determined in accordance with the requirements of the legislation and the time period during which inspections may be carried out by the competent authorities.

In all cases, the exact retention periods of personal data for each individual processing activity are recorded in the personal data processing register of AGRO.VI.M., as provided for by the GDPR. You may obtain detailed information regarding the specific retention periods of personal data by submitting a relevant request in accordance with the procedure provided for in this Policy.

6. RIGHTS OF DATA SUBJECTS

You may exercise, as applicable, the rights arising from the applicable Greek Law and the General Data Protection Regulation (Regulation (EU) 2016/679), which are as follows:

a. Right to be informed (Article 13),
b. Right of access (Article 15),
c. Right to rectification (Article 16),
d. Right to erasure “right to be forgotten” (Article 17),
e. Right to restriction of processing (Article 18),
f. Right to data portability (receiving personal data in a structured and commonly used format,
Article 20, where applicable), and
g. Right to object (Article 21), which applies to certain data processing activities.

These rights may be exercised only in cases where AGRO.VI.M. acts as the data controller, specifically:

a. in the processing of personal data of job applicants for the purpose of evaluating the possibility of
future professional collaboration,
b. in the processing of personal data related to the pursuit of the statutory purpose (trading/export
of products),
c. in the processing of customer data within the framework of evaluating and handling
complaints/requests,
d. in the processing of data of suppliers/partners in the context of invoicing,
e. in the processing of personal data through the Website.

These rights can be exercised free of charge by sending a relevant letter to the Data Protection Officer of AGRO.VI.M.: Latsoudis & Partners Law Firm, Akti Miaouli 3, Piraeus, Attica, tel.: +30 210 2205 950, or by email at dpo@latsoudislaw.com.

You may also submit your request in writing to: Complaints & Customer Service Department of AGRO.VI.M.: privacy@agrovimsite.codemonkeys.dev, or write to us at: AGRO.VI.M. S.A., Paradisou St. 14A and Patroklou St. 1, Marousi (PC 15125, Athens), tel.: +30 210 6423614.

  • However, if the above rights are exercised abusively and without reasonable cause, thereby causing administrative burden, we may charge you for the cost associated with exercising the respective right.
  • If you exercise any of your rights, we will take all appropriate measures to fulfill your request within thirty (30) days of receiving the relevant request. We may either inform you of the acceptance of your request or provide any objective reason preventing the processing of your request.
  • Regardless of the above, you have the right at any time to object to the processing of personal data, withdrawing your consent (Article 7, para. 3 of GDPR 679/2016) by sending a letter to the Data Protection Officer (DPO) of AGRO.VI.M.: Latsoudis & Partners Law Firm, Akti Miaouli 3, Piraeus, Attica, tel.: +30 210 2205 950, or by email at dpo@latsoudislaw.com. This right applies only in cases where the lawful basis for processing personal data is the consent of the data subject.

7. PROCESSING OF DATA BY AGRO.VI.M.

AGRO.VI.M. applies appropriate technical, physical, and administrative security measures throughout the data processing procedure to protect and secure personal data against loss, misuse, damage or alteration, unauthorized access, and disclosure, in accordance with Article 32 of the General Data Protection Regulation (EU) 679/2016, to ensure an adequate level of security against these risks. These include, among others, depending on the case:

a. the implementation of encryption protocols,
b. he ability to ensure confidentiality (Article 90 of the General Data Protection Regulation (EU) 679/2016), integrity, availability, and resilience of processing systems and services on an ongoing basis,
c. the capability for timely restoration of availability and access to personal data in the event of a physical or technical incident,
d. the process of regular monitoring, evaluation, and assessment of the effectiveness of technica and organizational measures to ensure the security of processing.

Furthermore, AGRO.VI.M. takes measures to ensure that any individual acting under the supervision of the data controller, who has access to personal data, will process such data only under the instructions of the data controller and will restrict access to personal information to authorized employees. Indicative security measures applied by AGRO.VI.M. are as follow:

Organizational Security Measures

  1. Appointment of a Data Protection Officer
  2. Organization/management of personnel, assignment of roles and responsibilities to individuals involved in processing personal data
  3. Management of information assets
  4. Training personnel on personal data security, informing them about AGRO.VI.M.’s policies/procedures
  5. Management of data processors
  6. Establishment of procedures for data and storage media destruction
  7. Management of personal data breach incidents
  8. Monitoring of security measures

Technical Security Measures

  1. Access control
  2. Backup copies
  3. Computer configuration
  4. Logging of user actions and security events
  5. Communication security
  6. Management and protection of external/removable storage media
  7. Security of accounting systems and applications
  8. Change management

Physical Security Measures

  1. Physical access control
  2. Environmental security – protection against natural disasters
  3. Document exposure
  4. Protection of portable storage media

8. COOKIES & OTHER TECHNOLOGIES

  1. What cookies are and why AGRO.VI.M. uses them: Cookies are pieces of information, usually in the form of very small text consisting of letters and numbers, stored in the browser used by each User/Customer (Chrome, Mozilla Firefox, etc.), helping the Website function more efficiently. Cookies in no way cause damage to users’ computers or the files stored on them. The information stored in cookies is used for identification purposes. This way, we are able to operate the Website efficiently.
  2. Cookies never contain personal information or any information that would allow anyone to contact the Website visitor via phone, e-mail, etc. Moreover, cookies do not grant access to documents or files on your computer.
  3. Which cookies we use: The cookies described below may be stored in your browser. You can view and manage cookies in your browser (mobile browsers may not offer this visibility). From the different types of cookies, the Company uses the following:
    • Technically necessary cookies (Cookieconsent, ccConsentUser, __cfduid)
      These cookies are essential for browsing the website and its functionality, as they store the visitor’s consent while navigating the Website. They also ensure secure user recognition, processing of navigation requests on web pages, secure login to Google accounts, etc. Data retention periods: Cookieconsent 1 year, ccConsentUser indefinitely, __cfduid 29 days.
    • Statistics/analysis cookies (_ga, _gat, _gid, collect)
      These cookies collect information about how visitors use our website, e.g., which pages are visited most often. They collect aggregated, anonymous information and are used exclusively to improve website performance. These cookies remain stored on the user’s device for more than one session, except for the Collect cookie, which expires at the end of the session, allowing the user’s preferences or actions to be remembered throughout the website. Data retention periods: _ga 2 years, _gat 1 day, _gid 1 day, Collect expires at the end of the session (session cookie).
  4. Technically necessary cookies are essential for the proper functioning of the Website, allowing you to browse and use its functions. These cookies do not identify your individual identity. Without them, we cannot provide effective Website functionality.
  5. If the User/Customer accepts the use of cookies, the following types of cookies may also be used: preference cookies, statistics/analysis cookies.
  6. Do not want to use cookies? You can enable, disable, or completely delete cookies used by AGRO.VI.M. through the browser settings. For example, in Chrome, you can select the Chrome menu, then Settings/Privacy/Content Settings, and adjust cookie settings according to your preferences. If you choose to disable cookies, certain parts of the Website or application may not function properly.
  7. You can also visit www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please note that if cookies are not enabled or are disabled, some Website functions may not operate as intended.
  8. The Website software is designed to ensure maximum security and trust. All information submitted via the Website is equally secure and confidential. Only authorized employees with appropriate training in handling users’/customers’ personal data will have access to this information, and only when necessary to fulfill requests and execute the relevant contract.
  9. AGRO.VI.M. uses third-party social networking widgets or buttons to provide additional functionality, allowing the Website’s content to be shared through social networks and via e-mail.
  10. Using these widgets or buttons installs a cookie on the user’s device, which facilitates the service, ensures the user’s interactions are reflected on the Website (e.g., counting social media followers), and tracks the user’s activity across the Internet and AGRO.VI.M.’s Website. AGRO.VI.M. encourages reviewing each provider’s privacy policy before using such services.
  11. For more details on the use of widgets and social media applications, you can visit the following links:
    Facebook Button – read their Data Policy: https://www.facebook.com/policy.php
    YouTube Button – read their policy: https://policies.google.com/privacy?hl=el
    Instagram Button – read their policy: https://help.instagram.com/155833707900388

9. SUBMISSION OF COMPLAINT – APPEAL

  • For any issue regarding the processing of your personal data, you may contact us via e-mail at privacy@agrovimsite.codemonkeys.dev.
  • Moreover, you shall always be entitled to contact the Hellenic Data Protection Authority, to submit a complaint on the Authority’s official website: https://www.dpa.gr/el/polites/katagelia_stin_arxi.

10. AMENDMENTS

This Policy may be updated from time to time due to changes in applicable legislation or modifications in the corporate structure of AGRO.VI.M. Therefore, we encourage Customers/Visitors to periodically visit this Website to stay informed about the latest information regarding personal data protection practices. In any case, Customers may also be notified via e-mail or a notice on our Website regarding any amendments to this Policy.